Submitted by: David L. Thomas

210 Peninsula Circle

Newnan, GA 30263

770 253-1060

David@DavidLThomas.com 

Scope: Enhance the academic community awareness and augment real estate 

listing videos by using the Phantom Vision3 and the inspire 1 Unmanned 

Aircraft System to conduct aerial photography and videography of real 

property. 

Request: An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a), 

91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) of Title 14, Code of 

Federal Regulations (14 CFR) as was granted to Douglas Trudeau, Realtor® 

in Exemption No. 11138. 

Petition: 

The following documents are included with the Petition: 

Phantom_3_Professional_User_Manual_v1.0_en.doc, 

Inspire_1_User_Manual_v1.2_en.doc, 

Safety_Guidelines.doc

Atlanta sectional map with anticipated operating area.

I request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 

91.417(a) and (b) Maintenance Inspections since they only apply to aircraft 

with an airworthiness certificate. I will, however, perform a preflight 

inspection of my UAS before each flight as outlined in the operating 

documents. 

UAS Pilot in Command (PIC) The Pilot in Command of my UAS will hold a 

Private Pilot's license, a third class medical certificate, and will have 

many hours of practice and, when one is available, attend the Phantom Pilot 

Training Course offered by the manufacturer. 

UAS Operating Parameters 

I request exemption from § 91.151. The Pilot in Command will abide by the 

following personal protocols and controls: 

 Pilot in Command will only operate in reasonably safe environments

that are strictly controlled, are away from power lines, elevated 

lights and airports. Pilot in Command will conduct extensive preflight 

inspections and protocols, during which safety carries primary 

importance; 

 Operate the UAS below 300 feet and within a radius distance of

1000 feet from the controller while maintaining direct line of sight 

visual observation (VLOS); 

 Land the UAS prior to the manufacturer's recommended minimum

level of battery power; 
 Use the UAS' GPS flight safety feature whereby the aircraft hovers

and then slowly lands if communication with the remote control pilot 

is lost; 

 Pilot in Command will conduct all operations under my own

personal and flight safety protocols (including posting a warning sign 

reading: "Attention: Aerial Photography in Progress - Remain Back 

150 feet") contained in the operating documents and will actively 

analyze flight data and other sources of information to constantly 

update and enhance my safety protocols; 

 Contact respective airports and/or Flight Standard District Offices if

operations will be within 5 miles to advise them of my 

estimated flight time, flight duration, elevation of flight and other 

pertinent information; 

 I will always obtain all necessary permissions prior to operation;

and 

 Have procedures in place to abort flights in the event of safety 

breaches or potential danger. 

§91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. I assert that since there is currently no certificate applicable to 

my operation, this regulation is inapplicable. 

§91.119 prescribes safe altitudes for the operation of civil aircraft, but it 

allows helicopters to be operated at lower altitudes in certain conditions. 

Pilot In Command will not operate the UAS above the altitude of 300 feet 

above ground level (AGL) and will also only operate in safe areas away from 

the public and traffic, thus "providing a level of safety at least equivalent to 

or below those in relation to minimum safe altitudes." Given the size, 

weight, maneuverability and speed of my UAS, an equivalent or higher level 

of safety will be achieved. 

§91.121 Altimeter Settings is inapplicable since my UAS utilizes electronic 

GPS with a barometer sensor. 

Public Interest Aerial videography for geographical awareness and for real estate 

marketing has been around for a long time through manned fixed wing aircraft and 

helicopters, but for small business owners, it's expense has been cost-prohibitive. 

Granting this exemption to me would allow me to provide this service at a much 

lower cost. My UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to manned aircraft. The operation of my UAS will 

minimize ecological damage and promote economic growth by providing 

information to companies looking to relocate or build in the Atlanta city and 

surrounding area.